LatviaRequirement-Rule: On 5 March 2020, the Latvian Official Gazette published the law implementing the directive on the mandatory automatic exchange of information in tax matters connecting to cross-border arrangements.
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SerbiaSimplified interest rates: On 6 March 2020, the Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook entered into force on 14 March 2020.
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BelgiumNumber of years to be compared: On 25 February 2020, the Belgian tax authorities published the final version of the transfer pricing (TP) Circular No. 2020/C/35. For comparability analysis, the tax authorities expect taxpayers to take into account at least 3 years of comparables, whereas only one year is examined for the tested party.
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USRestriction on interest deduction: The CARES Act increases the business interest expense limitation from 30% to 50% of adjusted taxable income (i.e., effectively EBITDA) for tax years beginning in 2019 and 2020.
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GuatemalaFiling Return: SAT has extended the income tax return the 31 March 2020 tax filing deadline to 15 April 2020 that corresponds to the fiscal year 2019 for companies and the 2019 transfer pricing information return.
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South AfricaMAP: On 20 March 2020, South Africa’s Revenue Service (SARS) has issued an updated guide on Mutual Agreement Procedures (Issue 3) for taxpayers. The guide addresses issues such as when MAP applies, when MAP may be denied, and how taxpayers should make a MAP request.
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Hong KongCbC reporting requirement-Timing: Hong Kong extends the deadline for notification in relation to Country-by-Country (CbC) reporting in response to COVID-19 pandemic to 1 June 2020.
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Information exchange-Bilateral: On 4 March 2020, the Inland Revenue Department (IRD) of Hong Kong announced that Mainland China and Hong Kong have entered into a bilateral arrangement for the automatic exchange of Country-by-Country (CbC) reports.
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Sri LankaSpecific TP compliance-Form: On 20 March 2020, the Inland Revenue Department (IRD) of Sri Lanka has announced that the deadline for submission of the transfer pricing disclosure Form has extended to 30 April 2020.
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UKSpecial rules for hybrid instruments or entities: On 19 March 2020, the tax authority the United Kingdom has issued a consultation document for public comments on the impact of hybrid mismatches rule. The consultation will last 10 weeks from 19 March 2020 to 29 May 2020.
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LuxembourgRequirement-Rule: On 21 March 2020, the Luxembourg Parliament approved draft law 7465 implementing the Council Directive (EU) 2018/822 (commonly known as DAC6) which introduces disclosure obligations for intermediaries and taxpayers of certain reportable cross-border arrangements.
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Saudi ArabiaFiling Return: On 20 March 2020, the Ministry of Finance of Saudi Arabia issued a statement on its website regarding postponement of Zakat returns filing, paying taxes among other procedures for the fiscal year 2019 in response to COVID-19.
Specific TP compliance: Filing of controlled transaction disclosure form and maintenance of the Transfer Pricing Local file and Master file has also been extended by 3 months for the year that ended on 31 December 2019.
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FranceRequirement-Rule: On 19 March 2020, the Government published Decree No. 2020-270 dated 17 March 2020 in the Official Gazette which sets out the information that intermediaries and relevant taxpayers must report to the tax authority under DAC6.
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PortugalElements of minimum standards: On 28 February 2020, Portugal deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
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ColombiaSpecific TP compliance-Form: On 10 March 2020, Directorate of Taxes and National Customs (DIAN) of Colombia published Resolution No. 000019 updating informative transfer pricing return (Form No. 120).
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